O'Hanlon v The Information Commissioner & Anor [2025] UKFTT 1056 (GRC) (09 September 2025)

O'Hanlon v The Information Commissioner & Anor [2025] UKFTT 1056 (GRC) (09 September 2025)

The appellant's request was the latest in a decade-long series of repetitive and overlapping requests concerning the same underlying issue, with diminishing public interest and value. The request was convoluted, burdensome, and caused distress to staff. The Cabinet Office was entitled to refuse the request as vexatious under section 14(1) FOIA, and the Information Commissioner correctly exercised discretion in upholding that refusal.

Citation
[2025] UKFTT 1056 (GRC)
Parties
Appellant: Liam O'Hanlon; Respondent: The Information Commissioner; Respondent: The Cabinet Office
Jurisdiction
United Kingdom
Judgment Date
09 September 2025
Procedural Posture
First Tier Tribunal (general Regulatory Chamber) Information Rights Appeal / Final Judgment on Appeal
Outcome
Appeal dismissed
Legal Topics
Section 14(1) FOIA Vexatious Requests, Right of Access to Information, Delegation of Qualified Person Under FOIA, Public Interest Balancing, Tribunal Powers Under FOIA
Freedom of Information Administrative Law Information Rights Section 14(1) FOIA Vexatious Requests Right of Access to Information Delegation of Qualified Person Under FOIA Public Interest Balancing Tribunal Powers Under FOIA

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 5 Party arguments 2
Sign in to unlock

Parties

Liam O'Hanlon

Appellant

The Information Commissioner

Respondent

The Cabinet Office

Respondent

Procedural Posture

First Tier Tribunal (general Regulatory Chamber) Information Rights Appeal / Final Judgment on Appeal

Legal Issues

  1. 1 Whether the Cabinet Office was entitled to refuse the appellant's FOIA request as vexatious under section 14(1) FOIA
  2. 2 Whether the Information Commissioner correctly exercised discretion in upholding the refusal
  3. 3 Whether the appellant's request had sufficient public interest or value to outweigh the burden on the authority

Ratio Decidendi

The appellant's request was the latest in a decade-long series of repetitive and overlapping requests concerning the same underlying issue, with diminishing public interest and value. The request was convoluted, burdensome, and caused distress to staff. The Cabinet Office was entitled to refuse the request as vexatious under section 14(1) FOIA, and the Information Commissioner correctly exercised discretion in upholding that refusal.

Court Disposition

Appeal dismissed